USCIS Memo on Asylum and Benefit Applications from High-Risk Countries

U.S. C itiz ens hip a nd I mm igrat ion Ser vices Office of the Dire ctor Camp Sp ring s, MD 20588 - 0009 PM -602-0192 Decemb er 2, 2025 Polic y Memorandum SUBJECT: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries 1 Purpo se Effec tive immedia tely, this memora ndum dire cts U.S. Citizensh ip and I mmigration Ser vices (USCIS) personnel to: 1. Place a ho ld on al l Form s I -589 (Application for Asylum and for Withholding of Removal), regardless of the alien’s country of nationality, pending a comprehensive review; 2. Place a hold on pending benefit request s 2 for alien s from countries listed in Preside ntial Proclamation (PP) 10949, Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats, 3 pending a comprehensive review, regardless of entry date 4; and 3. Conduct a comprehensive re-review of approved benefit request s for alien s from countries listed in PP 10949 who e ntered the United States on or after January 20, 2021. 5 This memorandum mandates that all aliens meeting these criteria undergo a thorough re- review process, including a potential in terview 6 and, if necessary, a re- interv iew, to fully asse ss all na tional security and public safety threats along with any other related grounds of inadmissibility or ineligibility. 7 An individualized, case-by- case revi ew and asses sment will b e done of al l rel evant information and facts. USCIS will also conduct a comprehensive review of all relevant policies, 1 On June 4, 2025, t he P reside nt i ssue d Presi dentia l Procl amati on 10949, Restr ict ing the En try of Fore ign Nati onals T o Protec t the Uni ted Stat es Fr om For eign T error ists and Other Nati onal Secur ity and Publi c Safet y Thr eats. E xercis ing authorit y under section 212(f) of the Immigratio n and Nationality Act (I NA), the pro clamation imp oses restrictio ns, limit ations, and except ions on t he entry of alie ns fr om 19 hig h - risk c ountri es. Unde r INA 212(f), the P reside nt ma y suspend or res trict the entr y of any alie ns deeme d detri ment al to U.S. int erest s. Se e 90 FR 2449 7 (PDF) (June 4, 2 025). 2 The term “ benefi t re quest” in t his memora ndum d oes not i ncl ude USC IS sc reening ac tivit ies, includi ng credi ble fear, reasonabl e fear, saf e third c ount ry, thir d co untry re moval, and t hreshold s cree nings u nder t he As ylum Cooper ative Agreements. 3 This app lies to aliens who list one o f the 1 9 high - ri sk co untri es as their Country of Bir th or C ountry o f Cit izens hip. 4 I ncludin g Form I - 485 (A pplic ation t o Regi ster P ermanent Res idence or A djust S tatus), Fo rm I - 90 (Application to Replace Permanent Resident Card (Green Card)), Form N - 470 (A pplica tion to P reser ve Res idence for N atural izati on Purposes), Form I - 751, (Petition t o Remove Condit ions o n R eside nce), and Form I - 131 (Applic ation fo r Travel Documents, Parole Documents, and Arrival/Departure Records). 5 Entered ma y incl ude admi tted, ins pected, parol ed, or e ntere d wi thout ins pecti on. 6 Intervie ws for this populat ion s hall not be wai ved un der an y cir cumsta nce. For benefit req uest s wher e an inte rview i s not required, the case review and evaluation will determine i f the alien needs to appear at a USCIS office. 7 See INA 212(a)(3)(A), (B), and (F) an d 237(a)(4) (A) and (B).

PM-602-0192: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries Page: 2 procedures, and operational guidance for compliance, accuracy, and needed improvements during this time. This guidance outlines the adjudicative hold, procedural requirements, and processes for the re- review, interview, or re- intervi ew of af fected alien s. USC IS personn el are inst ructed t o priori tize national security and public safety concerns and ensure comp liance wi th al l appl icable l aws and regulations during the adjudication process. All findings must be documented in accordance with established protocols to support any subsequent determinations or actions. Backgr ound On January 20, 2025, the President issued Executive Order (EO) 14161, titled Protec ting the United States from Foreign Terrorist and Other National Security and Public Safety Threats. This order aims to saf eguard U.S. c itizens f rom alie ns who may see k to commit ter rorist acts, p ose thre ats to national security, promote hateful ideologies, or exploit immigration laws for malicious purposes. EO 14161 underscores the importance of vigilance during the visa issuance process to ensure that individuals approved for admission into the United States do not intend to harm Americans or compromise U.S. national interests. Recently, the United States has seen what a lack of screening, vetting, and prioritizing expedient adjudications can do to the American people. An Afghan national, Nasir Ahmad Tawhedi, planned a terrorist attack in the United States on Election Day 2024. Tawhedi pled guilty in federal court to conspiring and attempting to provide material support and resources to the Islamic State of Iraq and al - Sh am (IS IS). 8 In another instance, an Afghan national, Rahmanu llah Lak anwal, is suspected of planning and executing a terrorist attack in Washington, DC against two National Guard members, 9 one who was killed and another who remains critically injured. USCIS plays an instrumental role in preventing terrorists from seeking safe haven in the United States and ensuring that USCI S’ screening and vetting and adjudications prioritize the safety of the American people and uphold all U.S. laws. In light of identified concerns and the threat to the American people, USCIS has determined that a comprehensive re -review, potential interview, and re- interview o f all alie ns from high -risk countr ies of concern who entered the United States on or after January 20, 2021 is necessary. Lastly, USCIS may, when appropriate, extend this review and re- interv iew pro cess to alien s who en tered th e United State s outside of this timefr ame. USCIS re mains committe d to ensur ing that a ll aliens fr om high -risk countries of concern tha t entered the United States do not present threats to national security or public safety. To address vulnerabilities during this process, and in order to conduct a c omprehen siv e review o f all p olici es, procedures, and guidance, USCIS has determined that it must implement an adjudicative hold on all pending asylum applications, regardless of the alien’s country of na tionality, as well as pending benefit reques ts fil ed by aliens from high-risk countries outlined in PP 10949. This hold will remain 8 See Afghan National Plea ds Guilty to Plo tting Electio n Day Terror Attack in the Unite d States, U.S. Department of Just ice, J une 13, 2025. 9 See Terr orist Who Shot Tw o Nat ional Guar d Member s in D.C. W as Let into the Countr y by the B iden Adminis trat ion’s O perati on Alli es Wel come Pr ogram, U.S. Department of Homeland Security Pres s Release, November 26, 202 5.

PM-602-0192: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries Page: 3 in effect until lifted by the USCIS Director through a subsequent memorandum. Any requests to lift the hold due to litigation or other extraordinary circumstances must receive approval fr om the USCIS Director or Deputy Director. 10 Guidanc e USCIS ha s determined th e oper ational nec essity to ensure that all a sylum applicants and alie ns from high-risk countries of concern who entered the United States do not pose a threat to national security or public safety. This effort ensures that USCIS exer cises its fu ll authority to investigate immigration benefit requests filed by aliens who may pose risks to the national security and public safety of the United States, as outlined in DHS Delegation of Authority 0150.1, issued June 5, 2003. USCIS will conduct a thorough review on a cas e -by- case basis to assess benefit eligibility including whether: 1. The alien is li sted i n the Terro rist S creeni ng Dat aset (TSDS) as a Known or S uspected Terrorist (KST) under Tier 1 or Tier 2 classifications or is included in Tier 3 or Tier 4 of the TSDS with significant derogatory information related to the alien. 2. The alien is connected to prior, current, or planned involvement in, or association with, an activity, individual, or organization described in sections 212(a)(3)(A), (B), or (F), or 237(a)(4)(A) or (B) o f the Immigratio n and Natio nalit y Act (INA). 3. The alien is linked to prior, current, or planned involvement in, or association with, an activity, individual, or organization that may pose a risk of serious harm or danger to the community, including criminal conduct described in INA 101(a)(43), 212(a)(1)(A)(iii), 212(a)(2), 237(a)(2), or 2 37(a)(4)(A)(ii). 4. The alien is unable to establish their identity as outlined in PP 10949. 11 This process ensures that USCIS exercises its full authority to protect national security and public safety while adhering to the provisions of the INA and applicable laws. USCIS has considered that this direction may result in delay to the adjudication of some pending applications and has weighed that consequence against the urgent need for the agency to ensure that applicants are vetted and screened to th e maximu m degree possible. Ultimately, USCIS has determined that the burden of processing delays that will fall on some applicants is necessar y and appropriate in this i nstance, when weighed against the agency’s obligation to protect and preser ve national security. Within 90 days of issuance of this memorandum, USCIS will prioritize a list for review, interview, re - interview, and referral to ICE and othe r law enf orcement agen cies as appropriate, and, in consultation with the Office of Policy and Strategy and the Fraud Detection and National Security Director ate, issue operational guidance. Use 10 Any reque st for a n exem ption to the adjudi cati ve hold mus t be coordi nated w ith the Offi ce of P olicy a nd St rategy. 11 See USCIS Policy Manual, Volume 1, Genera l Poli cies and P rocedures, Part E, Adj udicat ions, Chapt er 8, Discretiona ry Analy sis [1 USCI S - PM E.8 ].

PM-602-0192: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries Page: 4 This policy memorandum is intended solely for the guidance of USCIS personnel in the performance of their official duties, but it does not remove their discretion in making adjudicatory decisions. It may not be relied upon to create any right or benefit, substantive or procedural, enforceable under law or by any individual or other party in removal proceedings, in litigation with the United States, or in any other form or manner.